Privacy Policy (STATUS: JANUARY 2020)

Introduction

ALPEIN Software SWISS AG (further ALPEIN Software) takes protection of your Personal Data very seriously. The following statement gives you an overview of how we protect your Personal Data.

This Privacy Policy applies to our product and informational websites (Websites), web versions of applications and administrative platform (Web Services), and interactions you may have with ALPEIN Software (service inquiries, feedback messages, etc.) by email, telephone, on social networks, etc.

If you do not agree with following below terms, do not access or use Web Services and Websites.

This Privacy Policy has been compiled to better serve those who are concerned with how their Personal Data is being used online. ‘Personal Data’ means any information relating to an identified or identifiable natural person (‘Data Subject’); an identifiable natural person is one who can be identified, directly or indirectly.

Please read our Privacy Policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your personal data.

1. Data we collect and receive

We collect different types of information to provide services to you.

When ordering or registering on our Websites and in Web Services, as appropriate, you may be asked to enter your name, email address, phone number, address or other details to process an order or to help you with your experience.

Information for marketing purposes may only be used with your explicit consent. You can withdraw your consent at any time.

Types of data we collect and receive:

1) Customer Data. This is your Personal Data which you use for registration and order of our products: registration email, telephone number, address, login and initial password (for some Web Services), support inquires/messages.

2) Marketing Data. If you subscribe to our special offers and discounts newsletters, your contact details for this purpose (email, possibly also phone number or address), as well as responses to our marketing messages will be of this type.

3) Workspace Data. All the data of your company instance which include all instance users, their data and settings, all instance settings. ALPEIN Software is only a processor for this data (Section 4 of this Policy). Customer has all the control over Workspace Data.

4) Website Usage Data. This data type includes server logs and cookies (more about cookies you will found in Section 5 of this Policy). We collect IP addressed, browser info (type and settings), date and time of Websites and Web Services access, language settings, device info (type, OS, settings), location info.

5) Operational Data.Our administrators can request your platform administrator for access to error logs in case of problems with the platform. ALPEIN Software does not have access to this data and can access it only with the consent of the customer.

2. How we use the data we collect and receive

We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features to identify users and provide them with products, support, services, mailings, sales and marketing actions, to meet contractual obligations, to increase the efficiency and operation of the Websites and Web Services, notify you of updates.

We use Customer Data to fulfill our contractual obligations and to support and inform customers.

We use Marketing Data for marketing communication. You can opt out at any time.

We only store your Workspace Data and have no access to it.

We use Website Usage Data to improve the performance of the Websites and user experience.

We use Operational Data to analyze of the platform and services errors in order to provide you quick and efficient respond in case of issues.

3. How we protect your data

We do not use vulnerability scanning and/or scanning to PCI standards.

We only provide articles and information. We never ask for credit card numbers.

We do not use Malware Scanning.

Your Personal Information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

We implemented a variety of security measures to maintain the safety of your Personal Information when you place an order.

All transactions are processed through a gateway provider and are not stored or processed on our servers.

Given the nature of Internet and data processing technologies, we cannot guarantee that data, during transmission through the Internet or while stored by our company, will be absolutely safe from intrusion by others.

4. Controller and processor

Our goal is to keep your personal data safe. We store data on our private servers. According to the GDPR, ALPEIN Software acts as a controller as well as a processor. Our responsibilities as the controller are carried out when the end consumers of our Websites, Web Services and applications provide their personal data within the platforms. We act as processor when providing our products and services exclusively under the client administration, but with hosting maintenance on our servers. Consequently, ALPEIN Softwares duties are restricted solely to the information storage without having access to the personal data of the users.

5. Do we use 'cookies'?

Yes. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to:

• Understand and save user's preferences for future visits.

• Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since every browser is a little different, look at your browser's help menu to learn the correct way to modify your cookies.

If you turn cookies off, some features will be disabled. It will make your site experience less efficient and may not function properly.

However, you will still be able to place orders.

6. Third-party disclosure

We do not sell, trade, or otherwise transfer your Personal Data to outside parties.

We do not include or offer third party products or services on our website.

We do not use social plugins on our websites so your data cannot be transferred to social networks providers.

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

1. By Law or to Protect Rights. If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law.

2. Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

3. Sale or Bankruptcy. If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity.

7. Use of Google services

We use Google Analytics to analyze our websites. Information generated by the analytic cookie about your use of our websites collects and transmits to Google Analytics and stored there. The transmitted data is aggregated and user IPs are anonymized. Your email, phone number, name, order details are not transferred to Google Analytics. Google privacy policy:

We have not enabled Google AdSense on our site but we may do so in the future.

8. Use of Matomo

This website also uses the web analysis service Matomo in order to be able to analyze the use of our website and regularly improve it. The statistics gathered allow us to improve our content and present it in a way that is more interesting for you as a user. The legal basis for use of Matomo is Art. 6(1) point (f) GDPR (Legitimate interest).

Cookies are stored on your computer for this analysis (see (5) for more details). The collected information is stored exclusively on our server in Switzerland. You can stop the analysis by deleting existing cookies and preventing storage of cookies. If you prevent the storage of cookies, please note that you may not be able to use this website to its full extent. Storage of cookies can be prevented through a setting in your browser.

This website uses Matomo with the extension “AnonymizeIP”. As a result, further processing of IP addresses takes place in truncated form; this can exclude the possibility of direct personal identification. The IP address provided by your browser through Matomo is not combined with other data collected by us. Your email, phone number, name, order details are not transferred to Matomo. About Matomo:

We also use the IPinfo plugin for Matomo which helps us customize your user experience, send location-based offers and avoid of misuse of our websites. More about IPinfo: https://ipinfo.io/cybersecurity.

9. Data subjects’ rights

(ACCESS, RECTIFICATION, RESTRICTION, ERASURE, PORTABILITY, OBJECTION)

You can at any time request for information what what types of your Personal Data are processed by ALPEIN Software, as well as to correct or delete such Personal Data.

If ALPEIN Software uses your Personal Data based on your consent or to perform a contract with you, you may further request from ALPEIN Software a copy of the Personal Data that you have provided to ALPEIN Software. In this case, please contact the email address below and specify the information or processing activities to which your request relates, the format in which you would like this information, and whether the Personal Data is to be sent to you or another recipient. ALPEIN Software will carefully consider your request and discuss with you how it can best fulfill it.

You can contact us at any time to:

- Request access to data that ALPEIN Software has about you, purposes and terms of your data storage and disclosure

- Correct any data that ALPEIN Software has about you

- Delete any data that ALPEIN Software has about you

If you have any additional questions about ALPEIN Softwares collection and processing of your data, please direct any such request to contact@alpeinsoft.ch.

You may decline to share certain personal data with us, in which case we may not be able to provide to you some features and services.

At any time, you may object to the processing of your personal data, on legitimate grounds, except if otherwise permitted by applicable law.

10. Privacy policy for applications

For users of our applications, there is a separate Privacy Policy. It differs from the policy for Websites and Web Services, so if you use our applications, you should be familiar with it: https://www.swiss-securium.ch/privacy-for-apps/.

11. Sensitive data

ALPEIN Software will not obtain or require disclosure of Sensitive Personal Data (such as ethnic origin, religion or medical records) but if you choose to provide such Sensitive Personal Data (for example, for storing in your CloudSecurium™ account), ALPEIN Software may assume such Sensitive Data is provided with your consent and can be processed by ALPEIN Software as it sees fit, unless otherwise notified by you to ALPEIN Software in writing.

When you store data in our web applications, we provide only secure storage and have no access to your Sensitive Personal Data.

12. Use of this website by children

This website is not intended for anyone under the age of 16 years. If you are younger than 16, you may not register with or use this website.

13. Fair information practices

We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

The time periods for which we retain your Personal Data depend on the purposes for which we use it. ALPEIN Software will keep your Personal Information for as long as you are a registered subscriber or user of our products or for as long as we have another business purpose to do so and, thereafter, for no longer than is required or permitted by law or ALPEIN Software's Retention Policy, reasonably necessary for internal reporting, to pursue legitimate business interests, conduct audits, comply with legal obligations, resolve disputes and enforce our agreements, or to provide you with feedback or information you might request.

15. Change of Privacy Policy

ALPEIN Software reserves the right to change this Privacy Policy due to the changings in functioning of our Websites, Web Services or applications. We will alert you about any changes by updating the “STATUS” date of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates.

15. Contact us

If you have questions or concerns regarding this Privacy Policy, or would like to update information we have about you or your preferences, please contact us by email at contact@alpeinsoft.ch or by one of the following additional methods:

In the Switzerland by calling us at +41 (0) 41 552 44 00 or by writing to us at: